CES Ltd Modern Slavery Statement 2023

MODERN SLAVERY STATEMENT

1 January - 31 December

We acknowledge and pay respect to the original and ongoing custodians of the land upon which we live, work, learn and teach. We commit to actively working alongside First Nations people for healing, reconciliation and justice. The Catholic education faith community is inclusive and acknowledges that we are all made in the image and likeness of God and we are created in love. People of all faiths, genders, sexualities, abilities and cultures are therefore respected equally in the Sandhurst Catholic community. We acknowledge the pain and suffering of all who have been hurt in body, mind and spirit by those who have betrayed the trust placed in them.

May we all stand tall, stand firm, grounded in truth, together as one.

CHILD SAFETY

and Sandhurst Catholic Early

committed to the safety, participation and empowerment of all children.

This statement has been made on behalf of Catholic Education Sandhurst Limited (CES Ltd) ABN 94 643 894 384 and Sandhurst Catholic Early Childhood Education and Care (SCECE&C) ABN 98 643 978 205. This statement is prepared pursuant to section 134 of the Modern Slavery Act 2018 (Cth) and covers CES Ltd as a single reporting entity.

Catholic Education Sandhurst Limited (CES Ltd)

ABN 94 643 894 384

Vic 3550

P: 03 5443 2377

E: enquiries@ceosand.catholic.edu.au

E: mslo@ceosand.catholic.edu.au

W: www.ceosand.catholic.edu.au

MODERN SLAVERY ACT 2018 (CTH) - STATEMENT ANNEXURE

Principal Governing Body Approval

This modern slavery statement was approved by the governing body of Catholic Education Sandhurst Limited as defined by the Modern Slavery Act 2018 (Cth)1(“the Act”) on Tuesday 14 May 2024.

Dr Daniel White Chair -

Catholic

Education Sandhurst Limited Board (CES Ltd Board)

Signature of Responsible Member

This Modern Slavery Statement was signed by a responsible member of Catholic Education Sandhurst Limited as defined by the Act on Tuesday 14 May 2024.

Most Reverend Shane Mackinlay Bishop of Sandhurst

VISION

The vision for education in Sandhurst is to provide, in partnership with our families, stimulating, enriching, liberating and nurturing learning environments in each of the Catholic school communities within Catholic Education Sandhurst Limited (CES Ltd) and the two kindergartens conducted by Sandhurst Catholic Early Childhood Education and Care Limited (SCECE&C Ltd). At the heart of this vision is our commitment to the ongoing duty of care that we have for the safety, wellbeing, and inclusion of all children and young people.

We believe:

that the Gospel is central to who we are, what we do, and how we act.

that we have a vital role in the mission of the Catholic Church to imagine and seek new horizons while respecting our Tradition.

that a strong sense of community is dependent on the quality of our collegial relationships.

that each person’s potential is fostered through the dedicated ministry of Catholic education. in leadership encompassing vision, innovation and empowerment.

MISSION

The ongoing mission of Catholic education remains the mission of the Church“to spread the Kingdom of Christ over all the earth”. Under the precepts of Canon Law (806 1), the Bishop watches over Catholic schools in the Diocese and provides general regulations for them. The Sandhurst Catholic school today responds to its mission by ensuring education is provided according to Catholic Teachings and Beliefs and by offering a particular cultural experience that is grounded in “... a Christian view of the world, of life, of culture and of history”. This translates into a Christ-centred ethos and worldview that permeates all aspects of school life including relationships, structures, liturgies, celebrations and routines, as well as the formal curriculum.

Catechism of the Catholic Church, n.863 Congregation for Catholic Education. (1997), The Catholic School on the Threshold of the Third Millenium, n.14

ABOUT US

The identity of the Sandhurst Catholic Schools and Early Learning Centres reflects the principles of Catholic social teaching, grounded in the person of Jesus and interpreted and enacted for the “common good” in response to the “signs of the times”. These principles require that the dignity and potential of each person be fully respected within a climate that is conducive to peace, security and development. This must find expression in the relationships, structures, curricula, planning, processes and care in the everyday life of the school and kindergartens.

CES Ltd Modern Slavery achievements in 2023

To begin the CES Ltd Modern Slavery eradication journey, several initiatives stated in 2021, when CES Ltd was formed, to build a framework for the future of CES Ltd. These initiatives were further developed and embedded in 2022 and 2023 with the below milestones achieved;

• Developed a Modern Slavery Action Plan, promoted on CES Ltd website to current and future suppliers.

• Included Modern Slavery clauses in supplier contract templates.

• Utilisation of Vendor Panel for tender processes to assist with supplier selection including responding to Modern Slavery requirements.

• Attendance at ACAN webinars.

Our plans for 2024

To strengthen our mitigation practices going forward the following initiatives are in development for 2024:

• A Modern Slavery communications strategy.

• Modern Slavery awareness training to be rolled out through a new training program currently being implemented (CompliLearn).

• Release the CES Ltd Procurement Policy with greater focus on striving to abolish modern slavery throughout our supply chain.

• A due diligence program for key suppliers.

• A supplier Code of Conduct.

• A contact system for escalation protocol and remedy pathways policy and framework review.

• Utilising the SEDEX (ACAN program) platform to identify and assess the risk of engaging various suppliers who may have a red flag for modern slavery practices in their operations.

• Continue our partnership with ACAN with guidance and support through their webinars and compliance program.

CES Ltd’s aspirational goal is to identify and eliminate all risks associated with modern slavery from our operations, business partnerships and supply chain.

FROM THE BISHOP

Most Reverend Shane Mackinlay DD and CES LTD BOARD CHAIR

Dr Daniel White

The Christian tradition affirms the inalienable dignity of each person: created in the image of God, with unique gifts and talents, connected with the whole of creation, enriched by relationships of friendship and love lived out in a shared common life, capable of astonishing creativity, insight and achievement, and invited into communion with the Triune God revealed by Jesus. This core Christian vision of the human person is fundamental to the mission of Catholic Education Sandhurst Ltd.

While the most immediate consequence of this principle is in the way that students are placed at the centre of Catholic education, it also directs the relationship that Catholic schools have to parents, staff and the broader community. Pope Francis has encouraged us to appreciate this community in widest possible sense, and we are becoming increasingly aware that our activities often have impacts stretching far beyond our local community.

There are many ways in which the various forms of modern slavery can affect the operations, business partnerships and supply chain of our schools, often in ways that are not immediately apparent. Practices such as human trafficking, child labour, and exploitation of workers for minimal or no wages are terrible abuses of human dignity and are contrary to the fundamental respect that Christians seek to promote for each person. Catholic Education Sandhurst Ltd and Sandhurst Catholic Early Childhood Education and Care Ltd is committed to doing all in its power to assist in eliminating these practices.

This is the third Modern Slavery Statement of Catholic Education Sandhurst Ltd since its new corporate structure was established in January 2021. We are very pleased to see that over the last year, the Company has taken significant steps to embed awareness of modern slavery in its operations, and to further identify and address ways in which it might be at risk of supporting modern slavery.

The Company’s plans for 2024 focus especially on communication and training across its schools, kindergartens and offices. This will assist in promoting wider awareness in staff and students and identifying both potential risks and potential opportunities for addressing them. We are confident that these strategies will help all involved in Catholic education in the Sandhurst Diocese to become more alert to the risks of modern slavery, and to act in ways that promote the dignity, freedom and wellbeing of each person.

Most Reverend Shane Mackinlay

Dr Daniel White Bishop of Sandhurst CES Ltd Board Chair

REPORTING CRITERION 2

Catholic Education Sandhurst Limited (CES Ltd) - Governance Framework

In 2021 the Bishop (Bishop Shane Mackinlay) established the Company, Catholic Education Sandhurst Limited (CES Ltd), to assume the ownership and operation of fifty-two Catholic schools previously operated in an unincorporated form, and to be responsible for the operation of any further schools that will be established by the Company referred to as (Sandhurst Catholic Schools). In addition, there is reponsibility for two Early Learning Centres operating as a subsidiary entity Sandhurst Catholic Early Childhood Education and Care Limited (SCECE&C Ltd).

The CES Ltd Board of Directors (the Board) has the responsibility to ensure the advancement of education through the operation of an effective system of Catholic education at all levels within the Diocese, always in accordance with the beliefs, traditions, practices and canonical decrees of the Church and Church Laws. The Catholic education provision of CES Ltd spans primary schools, secondary schools, and schools in specialist settings. It is the responsibility of the the Board to ensure that each school operated by the Company is fully compliant with all legal obligations and standards required of registered schools in Victoria. The Board is responsible for setting strategic direction and policies to achieve the above. It contributes legal, financial, and other professional expertise to the governance of the Company and is supported by an expert Board committee membership. The Board works to promote stability, confidence, mutual respect, and support in the relationships between all who exercise leadership and management. The Board must ensure CES Ltd schools comply with the minimum standards for school registration under Schedule 4 of the Education and Training Reform Regulations 2017 (Vic) (ETR Regulations).

REPORTING CRITERION 2

It is the role of the Board to make explicit the importance of system improvement, facilitate the achievement of high-quality personal learning outcomes for all students and the provision of educational environments in which all will continue to flourish. In so doing the Board ensures that all legal obligations and compliance responsibilities arising from being a Company are met, particularly the:

• key aspects of the Board’s legal obligations under the Corporations Act (i.e. Board of Director responsibilities)

• governance standards imposed by Division 45 of the Australian Charities and Not-for-profits Commission Act 2012 (Cth) (ACNC Act)

• minimum standards for school registration under Schedule 4 of the ETR Regulations, including all matters relating to Governance; Enrolment; Curriculum and Student Learning; Student welfare; Staff employment and School infrastructure

• Ministerial Order 1359 – Child Safe Standards - Managing the risk of child abuse in schools, the Board, as the school governing authority, is responsible for ensuring Sandhurst Catholic Schools embed a culture of child safety and operate in compliance of child safety requirements. These include, but are not limited to, ensuring the Company has suitable policies, which are enforced, and provide for child safety and strategies to reduce the risk of child abuse. All such policies are approved and mandated by the Board.

The Executive Director has delegated responsibility to report to the Board on the implementation of the policies:

• reviewing and ensuring the reliability and effectiveness of CES Ltd’s compliance and risk management systems covering all areas of operation from occupational, health and safety to privacy

• finance and audit management

• capital development.

For the purposes of school regulation, the Board is structured in a way to enable:

• effective development of strategic direction of Sandhurst Catholic schools

• effective management of the finances of Sandhurst Catholic schools; and

• fulfil its legal obligations in respect of each Sandhurst Catholic school.

REPORTING CRITERION 2

Child Safety, Audit and Risk Committee (CS,A&R Committee)

Supporting the responsibilities of CES Ltd and SCECE&C Ltd Boards are their respective CS,A&R Committees. The Terms of Reference of the committees state that the committees are to provide strategic advice and high-level thinking on matters pertaining to child safety, auditing, risk mitigation, financial and investment management, OH&S and modern slavery, ensuring quality reporting and compliance with statutory and regulatory requirements.

Sandhurst Catholic Early Childhood Education and Care Limited (SCECE&C Ltd)

SCECE&C Ltd was instituted by Bishop Shane Mackinlay to assume the ownership and operation of two existing Catholic early childhood education and care centres in the Sandhurst Diocese, with a growth strategy to develop further Early Learning Centres. From January 1, 2021, SCECE&C Ltd was an approved Provider with the Australian Children’s Education and Care Quality Authority (ACECQA) for the early learning centres at St Mel’s Kindergarten Shepparton and Assisi Kindergarten Strathfieldsaye. SCECE&C Ltd is a company limited-by-guarantee and registered with the Australian Charities-andnot-for-profit Commission. As a wholly owned subsidiary of CES Ltd, SCECE&C Ltd operates through an independent representative and expert Board of Directors and works in close collaboration and partnership with local Catholic and Government schools, parish communities and Diocesan agencies, to help ensure a continuity of growth and development for each child and their family.

REPORTING CRITERION 2

Educational and Office Services

Key Objective of CES Ltd

“To foster the academic achievement and spiritual formation of each student, in an environment and culture that is committed to pastoral care and wellbeing, including appropriate safeguarding strategies and policies. Such an education builds up independent, confident and creative learners who have a love of learning, a sense of curiosity, and respect for themselves and for others, including the poor and marginalised.”

Bishop Shane Mackinlay: CES Ltd Initial Directions 2020

For 169 years, Catholic schools have been an integral part of the Diocese of Sandhurst, with the first school opening on the Bendigo Goldfields in 1853. Since then, the network of schools has made a unique contribution to the life, faith practice, spirit and culture of parishes throughout this region. Sandhurst Catholic schools are proud to be part of the long tradition of Catholic education in Australia, providing countless young people with enriching experiences and skills they acquired in Catholic learning environments.

Today, CES Ltd oversees and operates fifty-two Catholic schools, offering Primary, Secondary, and Specialist Settings to cater for the diverse needs of the community. We take pride in our responsibility to provide high-quality education that upholds our values and traditions. Additionally, CES Ltd will continue to operate future schools established by the Company known as Sandhurst Catholic Schools, further expanding our contribution to the education landscape of the region.

REPORTING CRITERION 2

1.

REPORTING CRITERION 2

The CES Ltd Head Office Structure

The CES Ltd Head Office provides support for the management of all CES Ltd schools as well as SCECE&C Ltd. The CES Ltd Executive Director, together with the CES Ltd Executive Leadership Team, is responsible for providing leadership and direction across all areas of the company’s operations. This includes ensuring compliance with regulations and standards, as well as driving the continuous improvement of both CES Ltd schools and the CES Ltd Head Office. Their goal is to foster a culture of excellence and innovation while upholding the values of the Catholic education community.

In 2022, CES Ltd underwent a significant restructure and created a new team to oversee Strategy Risk and Governance. The purpose of this team is to ensure that CES Ltd are operating within Victorian Catholic Education Authority (VCEA)1, The Victorian Registration and Qualifications Authority (VRQA)2 and legislative requirements.

The two entities collectively employ a team of 109 staff members located across three regional locations: Bendigo (Head Office), Tatura, and Wangaratta.

The CES Ltd Head Office is deeply committed to fostering a collaborative partnership with each school and parish community, as well as the broader Catholic education community of Victoria. They are dedicated to working in a spirit of co-responsibility to shape the culture, improve performance, and enhance the capacity of both the schools and the Catholic Education Office.

REPORTING CRITERION 2

Operations and Supply Chains

As an educational institution our largest expenditure is the salaries of teachers, educators and support staff whose salaries and employment related costs represents the majority of the organisation’s annual expenditure. In 2023 CES Ltd had a total turnover of $350 million which includes all consolidated entities.

The total workforce profile of CES Ltd includes 2,687 direct employees, while the total number of goods & services, contractors and suppliers is in excess of 12,000.

Schools are supported through CES Ltd in providing support services to schools which include:

• Leadership

• Catholic Mission, Learning and Teaching

• School Development and Support

• People and Culture

• Student Pastoral Wellbeing

• Operations

• Strategy, Risk, and Governance

Delegations Framework

At present schools have full autonomy to engage suppliers, however as part of the incorporation changeover a Financial Delegation oversight and approval process has been implemented dependent on the value of the engagement. The purpose of the Delegations Framework is to establish a framework for delegating powers, duties or functions of the CES Ltd Board in a manner that facilitates efficiency and effectiveness and increases accountability in the operation of Sandhurst Catholic Schools.

Pope Francis’s message is to make a choice for respecting the rights and dignities of every human being by mitigating modern slavery risk in our supply chain and is the strategic goal for Procurement at CES Ltd.

“Every

person ought to have the awareness that purchasing is always a moral - and not simply an economic - act”

Pope Francis (2014)

REPORTING CRITERION 2

CES Ltd has developed the following procurement values to guide decision making.

Responsibility – In our mission as a Catholic faith community, we are committed to seeking ethical, sustainable, and socially responsible procurement as we strive to make a positive impact on the global climate and environment, support First Nations communities and abolish Modern Slavery throughout our supply chain.

Integrity - CES Ltd and Service Providers will observe the highest standards of ethics and integrity in undertaking procurement activities. All purchasing activities will comply with relevant legislation, regulations and CES Ltd policies. Service Providers will be treated fairly, respectfully and free from bias.

Clarity – We will drive transparency and accountability to support open, success-driven and respectful partnerships with our Service Providers. We strive for success with our partnerships because when our Service Providers succeed, CES Ltd and our school communities will thrive!

Community – CES Ltd greatly values our local communities and is committed to supporting and fostering prosperity with local businesses across the Sandhurst region. CES Ltd adopts Social Procurement practices to actively promote accessibility and inclusion across our Supply Chain seeking to create a positive influence and opportunities within local communities to support growth for First Nations communities, inclusion of all genders and sexualities and opportunities for Victorians with disabilities.

Balance - CES Ltd determines “the Best Value” for goods and services to balance cost, service, quality, reliability, innovation, ethics, sustainability and value alignment.

REPORTING CRITERION 3

Operational Risks

CES Ltd faces various operational risks that can have a significant impact on the organisation’s reputation and operations. One of the most critical operational risks is modern slavery, which is a grave violation of human rights that affects millions of people globally. CES Ltd has continued its partnership with the Australian Catholic Anti-Slavery Network (ACAN), allowing CES Ltd to establish a robust relationship that will continue to assist us to identify and assess risks within the organisation, reducing the chance of modern slavery practices within our supply chains.

The modern slavery operational risks outline three key areas that CES Ltd and SCECE&C Ltd need to consider identifying and addressing modern slavery risks within the organisation. These areas include supplier engagement, supply chain mapping, and due diligence.

Service Provider and Supplier engagement is a crucial component of modern slavery risk management within CES Ltd. Service Providers and Suppliers can pose a significant risk if they engage in unethical practices such as forced labour or human trafficking or unknowingly procure goods from high-risk international regions.

By engaging with Service Providers and Suppliers and ensuring that they adhere to ethical standards, CES Ltd can reduce the exposure to modern slavery risks. CES Ltd will also continue to encourage and support our schools with their Supply Chain in taking steps to mitigate modern slavery risks within their own supply chains.

Supply chain ‘Category Mapping’ is another critical aspect of modern slavery risk management that CES Ltd will continue to explore. The aim is to have a comprehensive understanding of our supply chains and identify any areas where modern slavery risks may exist. This includes identifying countries or industries that are at high risk for modern slavery and understanding the risks associated with specific products or services. Working towards categorising and mapping supply chains will enable CES Ltd Procurement & Contracts team to develop effective strategies to mitigate modern slavery risks and ensure that our organisation is not contributing to this issue.

Due diligence is the final area that CES Ltd will continue to focus on educating and supporting our staff, schools and SCECE&C Ltd centres to manage the operational risks associated with modern slavery. This includes reviewing Service Provider, Contractor and Goods & Services contracts and high expenditure goods and materials purchases, as the organisation become more resourced and mature in this area, assessing their labour practices, and monitoring their compliance with ethical standards.

With the support of the CES Ltd Board and the Child Safety, Audit and Risk Committee, CES Ltd has a Risk Management Framework that defines our risk operating model, appetite, responsibilities, and methodology.

REPORTING CRITERION 3

This Framework supports the approach to managing modern slavery risks through good governance and accountability following the ISO 3100:2018 Risk Management – Guidelines. Our Risk Management Framework and accompanying policies are crucial in effectively managing operational risks, including those associated with modern slavery. These documents provide a structured approach to identifying, assessing, and mitigating risks, and ensuring that we continue to operate in a responsible and sustainable manner.

Our People

CES Ltd takes the responsibility towards our staff, students and community very seriously. CES Ltd is committed to providing a safe and inclusive work environment where all employees and workers are treated fairly and with respect. CES Ltd believe that treating our staff well is not only the right thing to do, but it also makes good business sense, as it helps us attract and retain top talent and maintain our reputation as a responsible and ethical organisation.

To mitigate the risk of modern slavery within our operations, CES Ltd have implemented several measures. These include:

• Robust recruitment practices: CES Ltd have established clear policies and procedures for recruitment and selection, including background checks and references, to ensure that all employees and workers are recruited in a fair and transparent manner.

• Training and awareness: CES Ltd are introducing training and awareness programs for our employees and workers to help them recognise and report any signs of modern slavery or other unethical practices.

• Ethical standards and code of conduct: CES Ltd have established clear ethical standards and a code of conduct that all employees and workers are required to follow. This includes a commitment to respect human rights and to report any suspected cases of modern slavery or other unethical practices.

• Feedback mechanisms: CES Ltd is working towards establishing clear feedback mechanisms that employees and workers can use to raise concerns or complaints about any issues they may face at work.

In addition to these measures, the organisation is working towards having the appropriate resources to regularly review and monitor our operations to identify and address any potential risks of modern slavery. Our aim is to work closely with our suppliers and partners to ensure that they are adhering to ethical standards and that they are taking appropriate measures to manage any modern slavery risks within their own operations.

CES Ltd, believe that our people are our greatest asset, and are committed to treating them with the respect and dignity they deserve. By taking proactive steps to mitigate the risk of modern slavery within our operations, CES Ltd is not only fulfilling our responsibilities as a responsible organisation, but also contributing to a fairer and more just society.

REPORTING CRITERION 3

Through the ACAN Program, CES Ltd and SCECE&C Ltd continue to focus activities with suppliers of labour and the operational risk associated with the following labour supply chains:

Cleaning and security services

The cleaning and security sectors typically employ temporary migrant workers engaged via subcontracting arrangements with a high rate of noncompliance with workplace rights and entitlements. Equipment and consumables used in these sectors are largely manufactured overseas, predominantly in high risk countries such as China and Vietnam.

Facility management and property maintenance

The labour force used in facilities management generally consists of temporary migrant workers and often contracted through labour hire companies.

Labour Hire

Labour hire services pose a high risk for worker exploitation and modern slavery for several reasons, including:

• focus on low-skilled, low-paid, seasonal, temporary labour

• recruitment of potentially vulnerable people such as new migrants, temporary work visa holders, international students and undocumented workers

• deceptive and opaque practices trapping workers into exploitative situations

• demanding excessive fees for visas, travel and other work arrangements, leading to debt bondage

• coercive control, threats, withholding workers’ identity documents to limit their freedom of movement and social isolation from the community.

Waste management services

The waste industry (including recycling) is a dangerous sector for workers with significant Workplace Health and Safety (WHS) risks such as exposure to toxic materials and pathogens, use of heavy machinery and dirty work environments. Modern slavery risks are similar to those faced by cleaners. Subcontracting to small waste management companies is common across the sector as is the use of labour hire. Migrants and low-skilled workers are used in waste collection, handling and material recovery facilities.

REPORTING CRITERION 3

Supply Chain Risks

CES Ltd’s finance systems are currently decentralised, with finance accounting systems (Technology One, SAS and Synergetic) being used across the organisation as a finance function, as opposed to a complete Supply Chain Purchase to Pay (P2P) management system. The decentralisation of data and inconsistent data entry across these platforms requires future resource investment to manage supply chain risk and improve analysis and reporting in the future.

As such the volume of goods and service providers, and the risk analysis is a high-level view based on school and head office data. Using the data available from all CES Ltd entities capturing invoice history valuing $119m AUD to capture the top 50 suppliers of this data pool by spend as well as suppliers of key high-risk goods and services.

REPORTING CRITERION 3

Spend Data Analysis

CES Ltd High Risk Spend Categories

CES Ltd High Risk Spend for the calendar year 2023 was $36.2m from a total of 2,302 suppliers. The split between high and low risk for spend was 30% and 25% respectively and the number of suppliers was 18% high risk and 2% low risk.

Building & Construction related spending ($15.8m) presents the greatest spend risk for CES Ltd at 44% of total high risk spend, although the lower number of suppliers (261) helps mitigate this risk.

The Furniture and Office Supplies category accounts for the highest number of high-risk suppliers (688) and the second highest spend ($6.7m). These two spending categories account for 63% of CES Ltd high risk spend.

REPORTING CRITERION 3

REPORTING CRITERION 3

REPORTING CRITERION 3

When procuring goods and services the table below identifies 4 key risk factors which can indicate an increase of modern slavery in supply chains:

Sector

Example of Goods or Service with Potential Risk

Industry Sector CES Ltd and SCECE&C Ltd procures construction and facilities maintenance services, which are known to be high risk for both domestic instances of modern slavery and for the manufacturing of products used in the course of those operations.

Commodity or Product

Geographic Location

Specific products and commodities are deemed high risk by the US Department of Labor’s 2018 List of Goods Produced by Child and Forced Labor, the Global Slavery Index (GSI) and other international guidance materials.

The risk based on geographic location is based on the estimated prevalence of modern slavery and the government responses as outlined in the 2018 GSI. CES Ltd and SCECE&C Ltd predominantly engages Australian suppliers, it is recognised that goods and associated services may come from countries other than those of suppliers’ headquarters.

Workforce Profile In undertaking the supplier analysis, CES Ltd considered the type of labour involved in the production of our goods and services, particularly where low skilled, vulnerable or migrant labour is used, or where the work is deemed as ‘3D’ work (dirty, dull or dangerous).

Example of Labour Rights Risk

Forced labour in the production of building and construction materials

CES Ltd and SCECE&C Ltd recognises, for example, that electronic equipment contains metals and minerals that may be sourced from regions known to be at high risk of modern slavery practices.

For example, that electronic goods from Malaysia would be considered to be at high risk of modern slavery.

Cleaning services, may use vulnerable or migrant labour which the work is deemed as ‘3D’ work (dirty, dull, or dangerous).

Exploitation of such employment conditions, below award wages or docking of wages.

CES Ltd will implement a process to engage with high spend suppliers and invite them to join Sedex and Vendor Panel. In doing so, Service Providers, Contractors and Suppliers will be able to complete a comprehensive self-assessment questionnaire (SAQ). CES Ltd will have access to results of the SAQ and any corresponding red flags factors that may contribute to modern slavery practices. Currently CES Ltd has a decentralised data system and collation of this data is under development.

There is further risk associated with the uncontrolled expenditure in Staff Reimbursements. While there is an approval process in place for these expenses, there is no overall visibility for these costs and is considered a High Risk procurement activity. A review of this process may be required in future by CES Ltd.

.

REPORTING CRITERION 4

Actions taken to assess and address risks

In 2023 CES Ltd Procurement Team commenced tendering to mitigate risk in the high-risk area of Cleaning Contractors, as well as Chemical and Consumable suppliers with the aim to provide schools and offices with a Preferred List of Providers that have been vetted to Modern Slavery Risk and inducted with Modern Slavery Training.

The Procurement Team is continuing to work with Schools and Offices internally to promote and educate staff on the Procurement goal and values. These tools are to support our social value decision making processes in alignment with the CES Ltd Strategic Plan and Catholic Social Teachings and are designed to encourage a balanced, conscious, “moral decision” based on value alignment, that supports our strategic plan objections for “Responsible Stewardship Communities”.

The current practices involving the schools and offices using three different accounting systems and autonomy over supplier selection, has caused a high-risk issue with data integrity and insight reporting. Due to inconsistent data across various accounting systems, the consolidation of the information is difficult to gain category analysis of the Supply Chain.

CES Ltd has completed a number of actions to address modern slavery and the risks it imposes.

• Continued partnership with the Australian Anti-Slavery Catholic Network (ACAN)

• Modern Slavery Liaison Officers (MSLO), who lead the operational activities to identify and mitigate modern slavery risks within the organisation. The MSLOs works closely with the Executive Leadership Team to collaboratively work together for the organisation approach to modern slavery. The MSLOs participate in the ACAN monthly webinars and engage with ACAN expertise on a needs basis to assist in actions to address risk of modern slavery and keep informed of new initiatives and the risk management program activities.

• CES Ltd Modern Slavery Policy - CES Ltd implemented a Modern Slavery Policy in 2021. This Policy provides a robust framework to ensure compliance with the reporting requirements of the Act, whilst also providing guidance for staff not to knowingly use or contribute to modern slavery practices.

• The development of contractual clauses for standard contracts. CES Ltd will access ACAN guidance for comprehensive clauses for high-risk contracts.

• Completed a Modern Slavery risk assessment on Operations and Supply Chain.

REPORTING CRITERION 4

• Completed Modern Slavery awareness training through ACAN - The two MSLO have completed modern slavery training-learning modules and are developing a training session for all of the organisation. E-learning modules cover;

» ACAN- Modern Slavery 101

» ACAN- Business Relevance

» ACAN- Implementing a Modern Slavery Risk Management Program

• Commemorating the Feast Day of St Josephine Bakhita on the 8th February to recognise victims of modern slavery.

• CES Ltd Social Justice Reference Group initiatives / website

Supplier engagement in 2023

• CES Ltd continued to include modern slavery clauses in the terms of Service Agreements and in tendering RFP templates for offices and schools to include upfront information regarding Modern Slavery risk disclosure and information upon the request of CES Ltd.

• 57 suppliers became members of Sedex, one of the world’s leading ethical trade membership organisations, working with businesses to improve working conditions in global supply chains. The CES Ltd Procurement team now has visibility over these suppliers, Self -Assessment Questionnaire responses and social audit results.

• Sedex provided schools with the resources to help make sustainable and ethical sourcing decisions.

• The Guiding Principles of Procurement continued to support Schools and Business units to view Procurement activities as a conscious moral decision

• In 2023 CES Ltd conducted a tender for cleaning providers developed a preferred supplier list that included modern slavery requirements.

REPORTING CRITERION 4

Modern Slavery Action Plan and Road Map

CES Ltd is committed to following the 5 Step action plan as provided by ACAN to guide and support our processes and objectives to reduce the risk of modern slavery in our operations.

Progress has been made in this reporting period from the Road Map, and some actions have been achieved, but there are still areas of improvement and opportunities to build and educate all our staff and stakeholders.

5 Step Action Plan and Road Map

Areas in bold text, indicate action has been taken or under development.

STEP 1: Commitment

Engage top management and set direction

Establish a Modern Slavery Action Working Party

Define roles and responsibilities

STEP 2: Business State of Play

Understand what you are doing well and where your gaps are to manage modern slavery risks

Prepare and implement a modern slavery action plan or strategy to address your gaps

Monitor progress and ensure continual improvement

STEP 3: Supplier Risk

Prioritise suppliers based on potential risk and spend

Seek responses from suppliers on their modern slavery actions in EOI or tender processes

Clearly outline expectations to suppliers

STEP 4: Engage, Educate and Respond

Engage and train management, employees and contractors

Engage and educate highest priority suppliers

Establish remedy pathway to respond when slavery practices identified in operations or supply chain

STEP 5: Modern Slavery Statement

Prepare draft Modern Slavery Statement and submit to leadership for signature

Collaborate with ACAN participants to develop Modern Slavery Compendium and upload to Commonwealth Modern Slavery Statement Register

Publish Modern Slavery Statement on entity website

REPORTING CRITERION 4

Provision of Remediation Solution through ACAN

CES Ltd is committed to ensuring it provides appropriate and timely remedy to people impacted by modern slavery in accordance with the Commonwealth Modern Slavery Act 2018 – Guidance for Reporting Entities and relevant Australian laws.

Due to the complexity of remediation, the need for specialist resources and to ensure the most comprehensive and rights-compatible outcomes for people impacted by modern slavery, CES Ltd is utilising the Domus 8.7 program from ACAN - an independent program to provide remedy to people impacted by modern slavery.

CES Ltd has not had the opportunity to review the remediation program, but will enhance future directions through further policy development, detailed response procedures and engagement with Domus 8.7 and other civil society stakeholders. By partnering with ACAN, Domus 8.7, CES Ltd can help people impacted by modern slavery achieve meaningful outcomes that can be reported on and continuously improve risk management and our response.

Where CES Ltd is directly linked to modern slavery by a business relationship, CES Ltd is committed to working with the entity to ensure remediation and mitigation of its recurrence. Remediation obligations and expectations are included in contracts with high-risk suppliers who must notify and consult with CES Ltd to ensure victim centred remediation processes are implemented to the satisfaction of CES Ltd.

When suspicions of modern slavery practises come to our attention through whistle-blower or other channels, staff will contact the Modern Slavery Liaison Officers (MSLO) in the first instance. Then the MSLO will contact the relevant law enforcement agencies and/or Domus 8.7 for an assessment, investigation, action planning and implementation of a remediation process.

A documented remedy pathway is an important requirement of the Modern Slavery Act.

Through the ACAN Program, CES Ltd agencies have access to the expertise and independent advice available through Domus 8.7. CES Ltd agencies or parishes can make referrals of people impacted by modern slavery to obtain support, advice and guidance on how to respond to concerns.

The right to remedy is a basic principle in international human rights law. The provision of remedy involves a business implementing actions and processes to investigate and redress negative impacts on people involved in business operations and supply chains, and ensure future incidents are prevented.

REPORTING CRITERION 5

Domus 8.7 principles:

• Independent advice and support

• Ensuring people impacted are safe and protected

• Any work undertaken is with the full knowledge and consent of people impacted

• Human rights based approach

Domus 8.7 overview:

• A vital service and key element of the ACAN Program

• Addresses a key mandatory reporting requirement of the MSA

Measuring Effectiveness of actions taken

Modern Slavery Baseline

The Baseline data demonstrates continuous improvement and captures the direct impact of actions, and helps CES Ltd understand the pace of change and set future direction. The data demonstrates increased engagement with suppliers of goods and services. The increased completion of the ACAN supplier survey improved identification of suppliers where the completion of the SEDEX SAQ would support managing modern slavery risk in their own operations and supply chains.

REPORTING CRITERION 5

CES Ltd Board and Child Safety, Audit and Risk Committee will oversee the ongoing development of the planning and program to manage risks within our organisation of modern slavery. The ACAN Action Plan and Road Map provides a great base to build on our planning and our commitment from all staff and stakeholders.

REPORTING CRITERION 6

Maturity Assessment

The Maturity Assessment provided by ACAN replaced the previous Gap Analysis and assists entities in determining areas of focus. The Assessment helps focus on the maturity of our modern slavery risk management approach to aim for continuous improvement. The maturity scorecard is designed to provide a comprehensive view of our efforts across different key areas of operation, presented as pillars:

1. Business Process and Governance: Establishes the overarching structure and policies guiding our efforts, emphasising the importance of oversight and clear responsibilities.

2. Operations: Focuses on internal practices and how effectively we manage risks within our day-to-day activities.

3. Supply Chain: Examines our external partnerships and the mechanisms in place to assess and mitigate risks beyond our immediate operations.

4. Worker Engagement: Addresses how we manage worker engagement and the standards upheld to prevent exploitation.

5. Entity’s Program and Activities: Looks at the broader initiatives and engagements we undertake to combat modern slavery.

6. Grievance Mechanisms and Remediation: Evaluates the channels available for reporting concerns and the processes for addressing them. In line with best practice and reporting requirements, we measure the maturity across governance, risk assessment, risk management, and effectiveness measures.

This evaluation helps identify strengths and weaknesses in our approach, across the four areas, presented as sub-pillars:

• Governance: sets the framework for our work, with mature governance characterised by strong policies and processes, guided by oversight and accountability.-

• Risk assessment: identifies potential at-risk-areas in our operations and supply chain, upon which we can act. A mature risk assessment involves continuous monitoring and collaboration and allowing for the prioritisation of resources and mitigating actions.

• Risk management: evaluate how well we apply the mitigating actions, with mature efforts being proactive and adaptable to changing circumstances, and driving real and measurable impact.

• Effectiveness: measures the impact of our anti-slavery efforts and it is what holds us accountable. While many such metrics are proxy measures, a mature approach is one that provides a basis for ongoing improvement, ensuring efforts are impactful and contribute meaningfully to eradicating slavery.

REPORTING CRITERION 6

For 2023, CES Ltd’s score falls in the 31% - 50% range indicating an Emerging Practice level. Emerging practices represent methodologies that are recognised as efficient and effective in managing modern slavery risks, based on current knowledge and evidence. These practices are benchmarked and serve as models for emulation. This means our processes related to modern slavery risk management are well-defined, standardised, and integrated into the organisational culture and operations. The focus extends beyond individual projects to include organisation-wide standardisation and continuous process improvement accompanied by adequate staffing and resources

REPORTING CRITERION 6

REPORTING CRITERION 6

REPORTING CRITERION 6

REPORTING CRITERION 6

Consultation with Entities Owned or Controlled

This statement is provided as a single reporting entity, pursuant to section 13 of the Modern Slavery Act 2018 (Cth) and incorporates the activities and operations of the 52 Sandhurst diocesan schools and also includes subsidiary entity SCECE&C Ltd’s two early learning centres.

For the preparation of this statement the CES Ltd Chief Operating Officer consulted with different functional departments across CES Ltd and SECEC&C Ltd as well as ACAN and other participating members of the ACAN network.

This consultation with ACAN and other departments has informed the approach to ensure it is appropriate and effectively tailored to reflect our organisational context and will be an ongoing consultation process for future initiatives, activities and statements.

APPENDIX A

The Catholic response to modern slaveryAustralian Catholic Anti-Slavery Network

The Catholic Church has a history of anti-slavery action from working to end Transatlantic slavery to supporting people impacted by modern slavery and by tackling its root causes.

Catholic anti-slavery initiatives focused on prevention, support and systemic drivers are delivered across the world every day by clergy, lay Catholics, parishes and large organisations such as Caritas, the International Catholic Migration Commission and the Order of Malta. ACAN participating entities are united in the belief that action against modern slavery is fundamental Catholic Social Teaching. Pope Francis has called modern slavery “a crime against humanity.” He has pledged with other global religious leaders to rid the world of this affront to human dignity and human freedom.

Catholic schools, hospitals, aged care facilities, universities, community services, investment and finance are just some of the Catholic institutions that touch the lives of millions of Australians. 1 in 5 Australian children are educated in Catholic schools (approximately 800,000) and 1 in 10 hospital patients and aged care residents receive care in Catholic facilities.

The extent of the supply chains is therefore highly significant and constitutes the major exposure to modern slavery for Catholic entities in Australia. ACAN brings together Catholic entities to leverage their collective purchasing spend, share resources and coordinate action to manage modern slavery risk across their industry sectors.

Catholic entities participating in ACAN are strongly positioned to respond effectively to the statutory requirements in the Modern Slavery Act with a comprehensive risk management program. The Modern Slavery Statements of Catholic entities will also form a compendium of Catholic principles and action for the advancement of human dignity and the common good. CES Ltd and SCEC&C Ltd are proud to be working in partnership with ACAN and network participants to deliver on the commitment to end Modern Slavery.

APPENDIX C

Remediation Pathways

Domus 8.7

Through the ACAN Program, CES Ltd has access to the expertise and independent advice available through Domus 8.7. CES Ltd

Schools, Offices & Early Learning can make referrals of people impacted by modern slavery to obtain support, advice and guidance on how to respond to concerns.

Catholic Education Sandhurst Ltd